A telecommunications carrier subject to the § 186-e telecommunications excise tax that makes sales to a foreign carrier and accepts a resale certificate (Form CT-120) from the carrier lacking a New York State Certificate of Authority (“COA”) number cannot rely on the resale certificate to rebut the presumption of taxability with respect to those sales. Advisory Opinion, TSB-A-15(3)C, TSB-A-15(4)I (N.Y.S. Dep’t of Taxation & Fin., Mar. 12, 2015) (released June 2015). According to the Advisory Opinion, the taxpayer telecommunications carrier can still attempt to prove, through a refund claim or on audit, that the sales to the foreign carrier are for resale. The Department advised the carrier to collect the tax from any purchaser that does not have a COA, since the purchaser can seek a credit to the extent it can show that the purchase was for resale.